Eoghan Murphy (Dublin Bay South, Fine Gael) | Oireachtas source

That does not mean there is an exemption for all of them. There is a last man standing principle here. If there is a transfer between investment undertakings, the final transfer is when the tax is applied. I think the officials went through this in some detail at the technical briefing. If there is a transfer between investment undertakings, withholding tax will not be applied, but when the final investment undertaking occurs, an IREF taxable event withholding tax is then applied. That is the last man standing principle. That is where the point of taxation is.